Privacy Policy
Last revised on May 24, 2018, effective as of May 25, 2018

This privacy policy describes the information you may provide or we may collect when you use the personal finance software available through our websites, services and applications (known collectively as the "Service"). Our practices for collecting, using, maintaining and protecting that personal information is discussed here.

This policy applies to all information collected by or provided to the Service via our mobile and desktop applications used to access the Service, or other information provided through e-mail or other electronic communication between you and the Service.

"Users" are people who have created an account with us, and have logged into that account using any part of the Service, including the website pocketsmith.com and any mobile or desktop applications downloaded from pocketsmith.com.

Please carefully read this policy to understand our practices regarding personal information provided to, and collected by the Service. Your decision to use the Service indicates that you agree with our privacy policy.

PocketSmith reserves the right to modify this privacy policy from time to time, so please review it for updates regularly. The date at the top of this privacy policy indicates when it was last updated.

Your Personal Information

Information is collected, including personal information, in different ways when you use the Service. As used here, "personal information" means any information which identifies you as an individual, such as your name and email address.

You can choose to use the Service without supplying any personally identifiable information. Account registration requires a username, email address and password, which can all be created anonymously for the purposes of registering for the Service.

Once registered, the Service may collect various types of information about Users, including the below.

1. Financial institution and account information submitted as part of setting up the Service.

2. Account login information including user names, passwords and multi-factor authentication information for accounts you connect to the Service via bank feed aggregation. This information is passed to our bank feed provider for further processing, and is not stored on PocketSmith servers.

3. Financial account information from the accounts connected to the Service or manually imported into the Service, including account balance and transaction information.

4. Information about usage details about the devices you use to access the Service, including internet connection information, collected via the methods outlined below.

The information described above is collected via the methods outlined below.

1. By third party bank feed aggregation.

2. When a User provides the Service with the information directly.

3. Automatically as a User navigates through the website pocketsmith.com. Information collected in this manner may include usage details, IP addresses and other information collected through cookies or other tracking technologies, as described in our Cookie Policy.

Information provided to us by the User

While you are using the Service, you may voluntarily provide information in a number of ways, described below.

1. When filling in forms on our website or applications, in order to register for the Service using your email address, or otherwise complete tasks and enter information into forms when using the Service.

2. When you get in contact with us for assistance, to report a problem with the Service, or other general enquiries.

3. When billing information is entered upon purchasing a subscription for the Service.

4. When any optional response is submitted to surveys that PocketSmith asks you to complete.

Information collected automatically

As you navigate through our website pocketsmith.com and make use of the Service, we may use automated technologies to collect information on your usage of the Service. The information that may be collected includes:

1. Details of the device being used to access the Service, including operating system information.

3. Mobile device and other information when you open our official mobile applications. This helps us improve our applications, identify and fix bugs, and improve the performance of our mobile applications.

4. Crash and error information when an application error occurs.

The technologies we use for this automatic data collection includes cookies and other technologies such as "clear gifs". You can find more details on these in our Cookie Policy.

How your information is used

The information collected or provided to the Service is strictly used to enable PocketSmith to provide the Service. This is further explicated below.

1. To provide you with the Service.

2. To allow you to create an account with the Service.

3. To identify you and authenticate your devices to access the Service.

4. To understand your experience using the Service, so that we can improve the Service, applications and how we operate our business.

5. To communicate with you about your account with the Service, and notify you about important changes and technical notices or updates related to the Service.

6. To allow the connection of third party financial institution accounts to the Service, and to gather account balances and transactions from those third party financial institutions.

7. To allow the execution of any contracts that you enter into with the Service, including billing for the Service.

8. To provide you with email-based customer support, diagnosing reported problems, and responding to your comments or questions about the Service.

9. To complete any purpose that you provide the information for, or that we describe when the information is provided to the Service.

10. To protect against, and investigate any fraudulent, unauthorized or illegal activity.

Disclosure of your information

Under no circumstances will PocketSmith sell your personal information.

PocketSmith and use such data only in a non-personally identifiable manner to provide statistics about the use of PocketSmith to our community

We reserve the right to anonymise or aggregate financial data, through excluding all personal information that makes the data identifiable to an individual. This anonymous data is used to analyze usage patterns so that we can improve and enhance the Service, or to provide aggregate statistics about the use of PocketSmith to our community.

Personal information as described in this privacy policy may be disclosed:

1. To service providers, contractors or other third parties who are legally bound to keep your personal information confidential, and who only use the information for reasons the Service provides the information to them.

2. For the purposes of aggregating your financial accounts and information, via our third party bank feed provider.

3. To a third party purchaser or successor in the case of a sale, acquisition, merger, reorganisation or other transfer involving the Service, where the assets being transferred include the personal information held by the Service. Should such a transfer occur, we will use our best efforts to require that the new combined entity follow this privacy policy with respect to your personal information.

4. In order to complete any purpose that you provide the information for, or that we describe when the information is provided to the Service.

We may also disclose your personal information:

1. To comply with any court order, law or legal process, including to respond to any government or regulatory request.

2. To enforce or apply our terms of service and other agreements, including for billing purposes.

3. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PocketSmith Limited, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Data retention

Your data is retained for as long as your account with the Service is active. If you choose to delete your account with the Service, the following actions are performed.

1. All financial account and transaction information is permanently deleted from production databases.

2. All information is deleted from our third party bank feed provider’s database, including any username and password information stored.

3. All available tools are used with third party service providers to remove or anonymise any personal information stored.

Encrypted backups are stored at an offsite location, with strict access control policies in place for accessing and decrypting backups. Backups are retained for one year, before being permanently destroyed.

Correcting and accessing your personal information

You can access and correct your personal information provided to the Service by logging into the Service using a browser and visiting the User Preferences section.

How often will this Privacy Policy be updated?

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our policy for some operational, legal or regulatory reason. Please re-visit this Privacy Policy regularly to stay informed.

The date at the top of this Privacy Policy indicates when it was last updated.

Where can I get further information?

If you have any questions about our Privacy Policy, please email us at [email protected].